Case Summary (G.R. No. 112172)
Factual Background
The facts established by the Court of Appeals indicate that Lot 5155, previously submerged and in a salvage zone, was reclaimed by the PEA in 1982. In 1989, the PEA erected an office on the lot as part of the R-1 Toll Expressway project. In December 1992, de Leon commenced construction of bunkhouses on Lot 5155, claiming to possess the land for over fifty years without challenge, inheriting this claim from his father. Disputes arose when PEA officials attempted to prevent de Leon from further construction.
Procedural History
On January 15, 1993, after the PEA destroyed de Leon's constructions, he filed a complaint with the Regional Trial Court seeking damages and a preliminary injunction against the PEA and its officials. The court initially granted a temporary restraining order to maintain the status quo regarding Lot 5155. Following a hearing, it issued a preliminary injunction against PEA, which prompted the petitioners to seek a reversal in the Court of Appeals.
Issue at Hand
The main legal issue concerns whether de Leon and his siblings were legitimate owners of Lot 5155 by virtue of claiming ownership through possession for at least fifty years. The Court of Appeals had affirmed their claim based on this long-standing possession, but this ruling is substantially contested by the petitioner.
Legal Principles
The Supreme Court establishes that to acquire ownership of public land, an applicant must prove fee simple ownership. Any presumption of land ownership leans in favor of public dominion, requiring proof of government grant or long-standing occupancy in cases where the land has not been certified as alienable and disposable. In this instance, it was determined that while Lot 5155 was later certified as alienable and disposable in 1972, de Leon's assertion of ownership has not been substantiated by a legal title or proper possession as defined under existing statutes.
Court's Findings
The Court concluded that de Leon's claim of mere possession, while purportedly continuous for over fifty years, did not meet the statutory requirements for ownership or conversion of public land into private property. The survey plan for Lot 5155 was not approved until 1992, undermining the assertion of any rights to ownership that predated this certification. The Court emphasized that in the absence of a legal title derived from the state,
...continue readingCase Syllabus (G.R. No. 112172)
Background of the Case
- The case involves an appeal for certiorari from the decision rendered by the Court of Appeals, which upheld the ruling of the Regional Trial Court, Makati, Branch 135.
- The core of the dispute concerns the legal right of respondent Bernardo de Leon to peacefully possess Lot 5155, based on a cadastral map issued in 1962 and supporting documents.
Facts of the Case
- The Public Estates Authority (PEA) asserts that Lot No. 5155 was once submerged and part of a salvage zone until reclaimed in November 1982.
- In 1989, PEA constructed its field office on Lot No. 5155 as part of the Manila-Cavite Coastal Road Reclamation Project.
- On December 22, 1992, Bernardo de Leon began construction of two bunkhouses and fencing on Lot No. 5155, claiming to have PEA's approval.
- PEA's project manager, Ricardo PeAa, observed de Leon's activities and instructed security to prevent further construction.
- De Leon claims his family had possessed Lot No. 5155 for over fifty years without dispute, taking over from his deceased father.
- He provided evidence of possession through tax declarations and fencing efforts, asserting continuous possession since 1989.
Allegations and Legal Proceedings
- On December 27, 1992, security personnel under the PEA issued a directive to cease de Leon’s construction activities.
- Despite presenting his documents proving ownership to the security personnel, de Leon received a notice to vacate Lot No. 5155.
- On January 14, 1993, while de Leon was away, PEA se